7 replies to this topic

[MDemaso]

Good morning. 

Does anyone have any advise for how to prevent internal intentional food adulteration? For instance, how would you prevent a disgruntled employee from adding substances to ingredients in the plant?

[Scampi]

1. A whistleblower program in house where employees can report seeing things anonymously 

 

2. cameras in house

 

3. HR should have a code of conduct that includes disciplinary actions

 

4. training

 

5.  Relocating said employees to a different task(s)

 

6. Limiting access to parts of the facility to only required employees

[G M]

The general approach is to remove opportunity.  It is presumed that most people willing to do this don't want to get caught, so making it hard to achieve without detection is the general solution.

 

Make sensitive processes where there is opportunity to introduce a hazard highly visible, to other employees, supervisors, security devices, automated inspection equipment etc.

[TimG]

There was a free FDA created training slide document floating around a few years ago that dealt with this. It came out right around the time their FDP builder dropped and was geared toward proper completion of that.

If your company is an FDA regulated food manufacturer it ideally has tackled your question and documented that and ways it mitigates that risk on the FDP.

[AltonBrownFanClub]

As @TimG said, here is the FDA Food Defense 101 training.

It has videos in English and Spanish which may be helpful.

Food Defense 101 - Front-line Employee | FDA

 

I've taught this course to all new employees for years. It's been effective for me.

There is a training certificate at the end. Employees always like when they're given proof of the training.

 

I also include a Forensic Files episode in my Food Defense training.

The episode talks about a city-wide intentional adulteration event and the effects on local businesses.

It's available on YouTube. Just search "Forensic Files Salmonella" and you will find it.

[GMO]

It might sound daft but avoid disgruntling your employees is a good idea!  Ok I'm being flippant but a lot of the work on culture is about involving people and making sure that you hear and act on the voices of your teams.

 

But there will always be bad actors in places.  I've heard of some employers looking into social media etc but that's an ethical minefield.  Imagine if you refused to employ someone because they were a vegan or because of a post they'd written online?  Does not bear thinking about.

 

So part of your TACCP / threat assessment should be about in house incidents and risk of that occurring.  One of the aspects of this is looking for the highest risk places.  These are the ones where multiple batches could be impacted and there aren't many people about.  So, for example, when I worked in chocolates it might have been the chocolate tanks or filling manufacture which would be highest risk.  In Beverages, it was the syrup manufacture which was huge risk as it's a quiet area and could impact thousands of units.

 

Once you've identified these places, look at how you can derisk them.  As above, CCTV and the warning it's there is helpful.  But do remember if it's never looked at, people soon know.  Manning differently could help.  E.g. do you really need to cover breaks or could people take breaks together?  

 

I'd also have a whistleblower line.  

 

Lastly I'd also train your staff.  Ask them to look out for someone behaving unusually.  There was a case in the UK where someone got close to contaminating ready meals.  Might be worth training your staff that this is a real, genuine risk.  

 

Kerry Foods statement: 'No evidence' terror plotter poisoned ready meal sauces in Burton factory - Staffordshire Live

 

I'm sure some senior leader would object to training it thinking it would put the idea in someone's head.  Pah.  I'd much rather have all my good people looking out for the odd bad apple than assume they're all bad.

[MDemaso]

Thank you for the good advice.

It looks like it boils down to cameras, training, and awareness. 

 

We do have a room where we store flavors and partially used dry bags. I would think this would be the most vulnerable spot b/c no-one goes in there unless you need something.

 

Someone suggested using tamper proof stickers on the partial bags / bottles. Does anyone have any experience with these? The flavor containers are probably used in production several times before they are empty.

[TimG]

I've used tamper stickers, and I've used tamper evident tape when shipping LTL products (no ability to seal truck). Both worked great for their purpose, you can even get numerical/sequential stickers to match up with a BOL.

Were you thinking of using these in house? Is it on something people remove/replace often? Could you install a lock on the door of the high-risk room and control the keys?